United States v. Mario Rodriguez-Escalera
884 F.3d 661
| 7th Cir. | 2018Background
- State trooper stopped Moran's car for changing lanes without signaling; Moran (driver) and Rodriguez (front passenger) were detained.
- Moran's California license was suspended; trooper issued citations and planned to issue a warning; the encounter lasted ~33 minutes before a K-9 unit arrived.
- During the stop the trooper questioned the couple about travel plans (they said they were traveling from Los Angeles to New York; Moran initially said Rodriguez thought they were going to Pennsylvania as a surprise).
- Trooper summoned a narcotics K-9; after a negative sniff, trooper continued questioning, then obtained Moran's consent to search; officers found ~7.5 pounds meth in luggage and ~$28,000 in cash.
- District court suppressed the evidence, concluding the traffic stop was unlawfully prolonged and Moran’s consent was not voluntary; government appealed as to Rodriguez.
- Seventh Circuit affirmed: the extension of the stop was not supported by reasonable suspicion, and Rodriguez (though a passenger) may challenge the stop under Brendlin because the drug seizure flowed from the unlawful detention.
Issues
| Issue | Plaintiff's Argument (Gov't) | Defendant's Argument (Rodriguez / Moran) | Held |
|---|---|---|---|
| Whether the officer lawfully prolonged the traffic stop to await a K-9 and conduct a dog sniff | Trooper had reasonable suspicion based on nervousness, origin from Los Angeles (a major narcotics distribution area), conflicting travel plans, and multiple air fresheners | Detention was extended beyond mission of stop without reasonable suspicion; factors relied on by trooper were weak or explained innocently | Stop was unlawfully prolonged; objective facts did not support reasonable suspicion to extend the stop |
| Whether evidence from the vehicle search is admissible given consent and timing | Even if Moran consented, the consent occurred after the seizure ended; evidence derived from consent is independent | Consent was obtained during continued detention; district court found consent involuntary or at least product of unlawful seizure | The consent/search was tied to the unlawful seizure; evidence is fruit of the illegal detention and must be suppressed |
| Whether Rodriguez (passenger) has standing to challenge the search/seizure | Government: Rodriguez lacks standing to challenge the vehicle search itself if he had no possessory interest; any suppression should rest on Moran's consent | Rodriguez (invoking Brendlin): as a seized occupant he can challenge the lawfulness of the traffic stop and suppress evidence derived from it | Under Brendlin, passenger may challenge unlawful stop; Rodriguez entitled to suppression because evidence flowed from unlawful detention |
Key Cases Cited
- Rodriguez v. United States, [citation="575 U.S. 348"] (2015) (officer may not extend a traffic stop beyond mission absent reasonable suspicion)
- Brendlin v. California, [citation="551 U.S. 249"] (2007) (vehicle passengers are seized during traffic stops and may challenge the stop)
- Terry v. Ohio, [citation="392 U.S. 1"] (1968) (stop-and-frisk standard: specific and articulable facts required for intrusion)
- Illinois v. Caballes, [citation="543 U.S. 405"] (2005) (duration of traffic stop must be limited to tasks related to stop)
- Ornelas v. United States, [citation="517 U.S. 690"] (1996) (mixed review standard for suppression: factual findings for clear error, legal questions de novo)
- United States v. Wilbourn, [citation="799 F.3d 900"] (7th Cir. 2015) (Seventh Circuit standards on suppression review and passenger standing)